September 8, 2025

Lanny Baker
Chief Financial Officer
Etsy, Inc.
117 Adams Street
Brooklyn, NY 11201

        Re: Etsy, Inc.
            Form 10-K for Fiscal Year Ended December 31, 2024
            Filed February 19, 2025
Dear Lanny Baker:

       We have limited our review of your filing to the financial statements
and related
disclosures and have the following comment(s).

       Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to this letter, we may have additional
comments.

Form 10-K for Fiscal Year Ended December 31, 2024
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Comparison of 2024 and 2023, page 76

1.     Please quantify all factors cited as contributing to variances between
periods. In doing
       so, describe the relative degree of the impact of each of volume and
pricing referred to
       in the analysis of revenue. Refer to the introductory paragraph of Item
303(b) of
       Regulation S-K and (b)(2)(i) therein, and section III.D of Release No.
33-6835
       (501.04 of our Codification of Financial Reporting Policies) for
guidance.
 September 8, 2025
Page 2
Liquidity and Capital Resources
Historical Cash Flows
Net Cash Provided by Operating Activities, page 81

2.     Net cash provided by operating activities increased $47.0 million in
2024 compared to
       2023. We note cash paid for income taxes, net of refunds, increased
approximately
       $47.0 million in 2024 compared to 2023 which decreases operating cash
flow for
       2024, though not described here as a material factor affecting operating
cash flows
       between periods. From the preceding, it appears there is $94 million or
more in factors
       contributing to the increase in 2024 not specified or quantified,
exclusive of the
       disclosed impact of decreased cash net income that is not quantified.
Please revise to
       specifically state and quantify all material factors contributing to the
change in
       operating cash flows between periods. Refer to the guidance noted above.
In regard to
       your reference to "cash net income," please explain to us and disclose
what this
       represents and how it is determined.

        In closing, we remind you that the company and its management are
responsible for
the accuracy and adequacy of their disclosures, notwithstanding any review,
comments,
action or absence of action by the staff.

       Please contact Robert Shapiro at 202-551-3273 or Doug Jones at
202-551-3309 with
any questions.



                                                           Sincerely,

                                                           Division of
Corporation Finance
                                                           Office of Trade &
Services